SecProbe.io

CORRESP
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March 6, 2018

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Attention:

        Jan Woo, Legal Branch Chief

        Office of Information Technologies and Services

    Bernard Nolan, Staff Attorney

 Re: Net Element, Inc.

Amendment No. 2 to Registration Statement
on Form S-3 Filed February 14, 2018

File No. 333-222466

This letter is on behalf of Net Element,
Inc. (the “Company,” “we,” “our” or “us”) in connection with the Company’s
amendment to Amendment No. 2 to Registration Statement on Form S-3 that was filed on EDGAR on February 14, 2018 (the “Current
Registration Statement”).

The Company is amended the Current Registration
Statement (by filing with U.S. Securities and Exchange Commission (the “Commission”), concurrently with filing of this
letter, Amendment No. 3 to Form S-3 (the “Amendment”)) to update its disclosure about the Company’s relationship
with Bunker Capital, specifically, termination of such relationship with Bunker Capital.

The Company is disclosing on pages
3 and 4 of the Amendment that (i) pursuant to a letter of intent between the Company and Bunker Capital, Bunker Capital
was going to assist the Company with its development of the blockchain technology, connection and the development of
smart contracts, suitable models, and implementation of an initial coin offering; (ii) as of the date of filing of the
Amendment, the Company has been focused on the development of the blockchain technology solutions and has not made any
commitment related to any digital securities offering and/or an initial coin offering should the Company decide to pursue
such an offering; (iii) as of the date of filing of the Amendment, Bunker Capital has not performed for the Company any
services related to any digital securities offering and/or an initial coin offering; (iv) as per the letter of intent, the
Company made a prepayment to Bunker Capital in the form of 19,000 shares of Company’s common stock; (v) the Company and
the technical and business team of Bunker Capital had several strategy planning meetings to discuss the architecture of the
ecosystem and related intellectual property matters; (iv) on February 26, 2018, the Company terminated the relationship with
Bunker Capital as the parties did not reach a definitive agreement; (vii) as part of such termination, the Company asked
Bunker Capital to return such shares of the Company’s common stock; (viii) at this time, the Company does not know
whether and how many shares will be returned; and (ix) the Company continues to work on the business plan and technology
schematics for such blockchain technology-based solution as part of its Netevia platform utilizing its internal team of
software engineers while continuing to assess the technical resources required to implement the Company’s strategic
initiatives in this regard.

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The Company hereby requests
you to advise the Company when it would be appropriate to request acceleration of the effective date of the Current Registration
Statement, as amended by Amendment No. 3.

If you have any additional
questions or comments, please feel free to contact me directly at 305.588.0122 or Serge V. Pavluk of Snell & Wilmer L.L.P.
at 714.427.7442.

Sincerely,

/s/ Jonathan New_______

Jonathan New

Chief Financial Officer

Net Element, Inc.

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